Angela M. Graham - Page 7

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          taxpayer was reasonable and the taxpayer acted in good faith.               
          Id.                                                                         
               Petitioner testified that she filed her 1991 Federal income            
          tax return based on the advice given to her by her attorney for             
          filing her 1983 Federal income tax return.  Petitioner further              
          testified that her 1991 Federal income tax return was filed                 
          consistent with prior returns.  We find petitioner to have been a           
          credible witness and find that her reliance on the advice of her            
          attorney constituted reasonable cause and good faith.                       
               Based on the record, we hold that petitioner is not liable             
          for the accuracy-related penalty pursuant to section 6662(a).               
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                             under Rule 155.                          






















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